p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

3) IV-B-3 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:46 AM Sheet 3 of 273 
P.2 

|\/~6-3 

MEMORANDUM 

TO: 

FROM: 

DATE: 

SUBJECT: 

REFERENCE: 

I. 

II. 

FINAL TRIP REPORT 

NONCONFIDENTIAL VERSION 

Project file of Reinforced Plastics Composites Manufacturing NESHAP 

Keith Barnett, U. S. Environmental Protection Agency, Emission 

Standards Division 

February 6, 2001, Revised May 6 and September 19, 2002 

Site visit to American Standard Inc. 

Reinforced Plastics Composites Manufacturing NESHAP, ESD Project 

No. 93/58 

INTRODUCTION AND PURPOSE 

The purpose ofthis visit was to obtain information on the reinforced plastic 

composites manufacturing operations at the American Standard facility located in 

Salem, Ohio. Specifically we wanted to focus on the capture and control of 

emissions from the manufacture of reinforced plastic bathtubs. 

PLACE AND DATE 

American Standard, Inc. 

605 South Ellsworth Avenue 

Salem, Ohio 44460 

February 17, 2000 

330-332-9954 

III. ATTENDEES 

FEB 2 7 K'B 

EPA AIR DOCKET 

American Standard - Corporate 

Mr. Ronald D. Barndt, Team Leader, Product Development 

Mr. Scott Flemming, Corporate Environmental Engineer 

American Standard - Salem 

Mr. Eugene (Gene) Garczewshi, Manager, Safety and Employment 

Mr. Mark Koepsel, Process Owner 

Mr. Karl T. Kuszaj, Chemist 

Mr. William Weltman, Environmental 
P.3 

Frees. Inc. (Thermal Oxidizer Vendor) 

Mr. Jack Hanley 

U. S. Environmental Protection Agency Representatives 

Mr. Keith Barnett, USEPA, Environmental Engineer 

Ms. Melanie Proctor, Pacific Environmental Services (contractor for USEPA) 

Ohio Environmental Protection Agency 

Mr. Darren J. Machuga, District Representative 

IV. SITE INFORMATION 

This site visit covered the manufacturing facility in Salem, Ohio. The company had 

prepared a detailed response to a list of questions for the facility prior to the site visit. This 

information is included as attachment 1. Subsequent to the site visit, American Standard provided 

information from the emission test report dated October 10, 1997. This information is included as 

attachment 2. 

American Standard manufactures reinforced plastic bathtubs. The tubs are made by 

vacuum forming an acrylic sheet, and then applying polyester resin and reinforcement to the 

acrylic. Using the acrylic sheets as the surface ofthe tub eliminates the need for gel coat in the 

production process. One reason given for converting to acrylic surfaces for the tubs from gel coat 

was this change eliminated the styrene emissions associated with gel coat application. This facility 

currently generates approximately 110 tons per year of styrene emissions for the production 

process operating at 24 hours per day, 7 days per week. By eliminating gel coat and applying a 

control device with a design efficiency of 95 percent, the facility's emissions would be below 10 

tpy, and therefore it would be a synthetic minor source exempt from Title V and NESHAP 

requirements. 

Figure 1 presents a process flow diagram ofthe bathtub production process. The formed 

acrylic shapes are placed on a conveyer belt and enter a spray area that was designed to be a 

permanent total enclosure. The entrance to the spray booth is an 8 x 5 foot opening hung with 

plastic strips. The strips are side by side with no gaps or overlap. The booth is 40 x 16 x 7 feet in 

size and has two spray stations. The acrylic sheet receives a first layer of laminate using an 

atomized chopper spray gun. The acrylic shape can spin on the conveyer to allow all sides to be 

accessed from one side ofthe conveyer. The next operator rolls out the laminate and adds 

additional plywood reinforcement. The third operator sprays a second layer of resin and 

reinforcement. The fourth operator does the final rollout. Therefore there are a total of 4 

operators in the spray booth any one time. The bathtub exits the spray booth through a 8 x 4 foot 

opening also hung with plastic strips with no gaps or overlap. 

The tub then enters a cure oven used to accelerate the cure process. The oven is 50 x 16 

x 5.5 feet in size, with an entry and exit openings of 16 x 5 feet, also hung with plastic strips with 

no gaps or overlap. Once the tub leaves the curing oven it is completely cured and there are no 

styrene emissions. 
American Standard, Inc. - Salem, Ohio 

Acrylics FRP Spray Booth - R008 

OJ 

Heated Air 

2.000 CFM 

FRP Laminated 

Bathing Vessels^ 

Products of Combustion 

(C02. H20 ,N2.02) <r 

Combustion 

Gases 

300 CFM 

/ k 

Contaminated Air 

2000 CFM 

i \ 

CURE 

Styrene Emissions 

STYRENE CONTROL 

DEVICE 

Styrene Emissions 

Combustion Air 

Contaminated Air 

28,000 CFM 

ROLL SPRAY WOOD SPRAY 

Heated 

Make-up Air 

25.000 CFM 

Thermoformed 

**•£ Acrylic Shapes 

Catalyzed, Riled 

Polyester Resin 

Glass Roving 

Ptywood 

Figure 1 FihftrglasR RatTvmh Pm^i^n n Pm^O Cn 
P.5 

Resin is stored in 2 storage tanks. The resin is pumped to the Nauta mixer where the filler 

is added. Resin is being mixed about 75 percent ofthe time. Mixed filled resin is then pumped to 

a holding tank beneath the Nauta mixer. The facility operates approximately 24 hours per day, 5 

days per week, and 50 weeks per year. (Since the site visit this process has changed. Currently 

the resin is pumped from storage to a shear mixer were the filler and a pigment are added. The 

mixture is then pumped to the Nauta mixer which is used as a holding tank and ta keep the 

materials mixed. Both mixers vent to the control device.) 

This facility also makes molds on site. There are two types of molds made. These are 

molds for the reinforced plastic bathtubs, and molds for the thermoform tooling operation. The 

mold spray booth is also designed to be a PTE and vents to the control device. The process flow 

diagram for mold production is shown in figure 2. 

Attachment 3 presents drawings ofthe plant floor layout showing locations of mixing 

areas and the mold making spray booth. Attachment 4 presents stack flow measurement data 

prior to installation ofthe control device. 

Emissions and Controls 

There are controlled three HAP emission points in this facility. These are the production 

spray and rollout booth and the cure oven, the mold spray booth, and a Nauta mixer. There are 

also 2 resin storage tanks that vent to atmosphere. Storage tank emissions are well below 1 tpy. 

As shown in figure 1, the production spray booth and cure oven exhaust 28,000 cfm to the 

control device. The measured 8-hour TWA's in this booth range from 78 ppm for operator #1 to 

18 ppm for operator #3. These tests were done with a collection pump. Employees in the spray 

booth wear respirators. 

The mold spray booth has an estimated exhaust rate of 7000 cfm. This spray booth 

operates 22 hours per day. Operation in the spray booth include making tools (molds), repairing 

tools, and production of durabond product (a specialized line of tubs). The exhaust fans for the 

mold spray booth are off when the booth is not in use. 

Both the production and mold spray booths were designed to be PTE. The production 

spray booth was also tested by the original air emission permitting authority. This local agency 

has since been disbanded and the permit is now handled directly by the State of Ohio EPA 

regional office. Based on a review ofthe EPA Method 204 requirements, it appears that the 

production spray booth as currently configured may not meet the 200 fpm air flow requirements 

at the entrance and exit. American Standard intends to make modifications to the spray booth to 

bring it into compliance. 
American Standard, Inc. - Salem, Ohio 

Mold Making Spray Booth - R018 

<-n 

Products of 

Combustion < 

(C02. H20, N2. 02) 

Polyester Molds for 

Manufacturing 

Styrene 

€mJssioFis 

Acetone 

Emissions 

Styrene Control Device 

Styrene 

Emissions 

Acetone 

Emissions 

Spray Booth 

v 

Master Molds 

Combustion Air 

Catalyzed, Filled 

Polyester Resin 

Glass Roving 

Steel Reinforcement 

Acetone 

Master Molds (-£ i x -jv$ ^ ) 

1 per day 1 per day 

Figure 2. Mold Production Process. 
P.7 

The Nauta mixer is a closed vessel that is vented to the control device. This is a low shear 

mixer type designed primarily for the mixing pharmaceuticals and rocket fiiel. There is a second 

mixer at the facility but the Nauta mixer is primary. The secondary mixer is not vented to the 

control device at the time ofthe site visit. (This mixer has been relocated, and is now primary. It 

is currently vented to the control device.) 

Figure 3 shows the process flow diagram ofthe control device. This is a Polyad system 

originally purchased from Weatherly. The original system had a catalytic oxidizer. However, the 

catalyst was continually fouling due to sulfur dioxide, chlorine, and silica present in the 

combustion air. The catalyst manufacturer suggested cleaning with sodium hydroxide. However, 

the plant opted to replace the catalytic oxidizer with a thermal oxidizer furnished by Frees, Inc. 

The styrene laden exhaust enters the adsorber and is adsorbed in a fluidized bed using 

Bonopore adsorbent. The absorbent enters the adsorber at the top, and moves downward 

through fluidized beds and exits the bottom ofthe adsorber. The clean exhaust then goes through 

a cyclone to recover any entrained adsorbent, is combined with the oxidizer exhaust, and then 

goes to atmosphere. 

The styrene laden adsorbent is conveyed in a closed system to the desorber tower. 

Ambient air passes through a heat exchanger and is heated to 250 degrees F. This is the minimum 

temperature necessary for desorption. The heated air flow into the desorber is 1100 to 1200 cfm. 

The heated air then flows up the desorber tower, desorbing the styrene. The desorption air then 

passes through the two filters and a recuperative heat exchanger and into the oxidizer combustion 

chamber. The combustion camber temperature is maintained at 1400 degrees F for 2 seconds. 

After combustion, the oxidizer exhaust is used to heat the incoming ambient air, is combined with 

the cleaned air exiting the adsorber, and exhausts through the single stack. The facility is planning 

to convert from one stack to two stacks, one for the oxidizer and one for the desorber. The total 

system static pressure drop is 19 inches of water. 

The control device has been tested twice. The first test was performed in September 1997 

and the results were a 94.7 percent destruction efficiency. A subsequent test performed in March 

of 2000 showed a destruction efficiency of 85.5 percent (90 percent removal in the adsorber, and 

95 percent destruction in the oxidizer). They have discovered several problems in the adsorber 

unit that are being corrected. Once the repairs are complete another emission test will be 

performed. 

Control Equipment Maintenance and Costs 

The original unit cost $495,000. The facility estimated that the capital cost of 

equipmentpurchased since was up to $1 million. 
m r mrr tt 

TOT*, imo c uni . 

4l»/Mt mi T 

Figure 3. Schematic of Polyad control device. 

00 
P.9 

The main operational problem with the Polyad system has been balancing the fans. There 

are two fans with different operating curves. Small changes in static pressure result in large 

changes in fan requirements, which results in an unstable system. The facility plane to replace one 

ofthe fans to correct this problem. 

The original control system had a cyclone between the desorber and the oxidizer to 

remove the entrained adsorbent. The cyclone proved to be inadequate because entrained 

adsorbent was plugging the oxidizer. They now have two filters between the desorber and the 

oxidizer. The first is an 1.25 inch thickness and the second is .25 inch thickness. 
P.10 

AMERICAN STANDARD INC. 

United States Plumbing Products Group 

605 S. Ellsworth Avenue 

Salem, OH 44460 

Telephone: 330-332-9954 

Telefax: 330-337-2235 Attachment 1 

Underlined information are notes made during site visit which were added to this attachment. 

Requested Information 

ADD-ON CONTROL DEVICE TECHNICAL DATA 

1. Hazardous air pollutant (HAP) concentration at the inlet to the control device: 

As a percentage of LEL (1.1% for styrene) the system typically runs at 7 to 

9% of the LEL. 

2. Flow rate to the add-on control device: 

35,000 aCFM of air, or 2555 #m/min 35,000 cfm is the design 

3. Annual operating hours ofthe control device: 

5,800 hours (116 hrs/week, 50 weeks per year) 

10-15 minutes are required to 

4. Status of control device during non-operational hours: start up the control device. 

During the week is full on This mav changes later to turning control off 

Weekends full off when spray booth is down. 

5. Confirm October 10, 1997 D.E. test report results for add-on control device 

Copy attached 

6. Method of demonstrating continuous compliance with D.E. 

Continuous Parameter Monitoring System as required by the permit 

Parameters monitored are: Desorber Bed Pressure Drop to be less than 5 

in.wc. Desorber exhaust temp less than 230°F, Minimum Combustion 

chamber temperature (Permit requires minimum of 550°F, for catalytic 

oxydizer, we now maintain 1400°F for thermal oxydizer, Catalyst bed inlet 

temperature (No longer applicable.) 
P.11 

7. Destruction Efficiency testing requirement: 

Permit renewal and/or at mid point of permit depending on permit language 

when issued. 

ADD-ON CONTROL DEVICE COST DATA 

1. Add-on control device capital cost and year of the cost data. 

$594,000 1995. Included adsorber desnriw 

2. Instrumentation cost, freight cost, and sales tax: '• 

Instrumentation and Freight are part ofthe above costs. 

Sales tax abatement received from the state of Ohio, see Air Pollution Control 

Certificate number 6294. 

3. Electrical Power consumption and cost associated with Add-on control 

device (Est. 1996): 100 hp main fan 

15 ho original fan f prior to installing controls") 

Annual Electric: $28,360 1 boost fan for mold making 

2 boost fans for production line 

4. Fuel usage and costs associated with add-on control device _. 

_ A . .„_,,„, , < New oxidizer. 

Currently rated at 0.24MBH max. rwinal oxidizer f catalytic) 

Runs at approximate 7/16 throttle: 0.10MBH h,H 7.5 mm BTU burner 

Cost: $2.41/DTH $5.78 per dav. aDDrox $127.25 per mo. 

("This is $2.41 per mm BTU/hr) 

5. Site preparation costs, and building cost to house control device: 

Foundation (Kreidler): $4326 Original charge of bonopore 

Structure & Housing (Diamond Steel): $33,600 was 4300 lb 

$37,926 

6. Control device maintenance costs, media replacement costs: 

Filters: 15 ea 6 times per year @ $38.19 $3437 per year 

Drive belts: 2 ea 1 time per year @ $180.00 ea $360 per year 

Media: 100 pounds per month @ $28.00/# $33,600 per year 

$37,397 per year 

Bonopore is grinding itself to 

powder and must be frequently replaced 

AtoMicm' Standard 

(0 
P.12 

7. Overhead, property tax, insurance, and administration costs associated with 

add-on control device: 

Overhead: Not available 

Property tax: Not available 

Insurance: Not available 

Administration Costs: Not available 

8. Record keeping and reporting time, costs associated, list of records and reports, 

and time and costs to prepare same: 

Records Time By *Costs 

Daily production report 15min/day WGM $3750/yr 

Daily resin usage 15min/day Resin Mixer $2625/yr 

Daily man-hours 15min/day WGM $3750/yr 

^ Daily maintenance log 20 min/day Millwright $2625/yr 

& Quarterly excursion report 20min (varies)/Qtr Env. Mgr $67/yr 

3*K Quarterly emission report 4 hpurs/Qtr Env. Mgr. $800/yr 

Quarterly production summary 1 hour/Qtr Env. Mgr $200/yr 

, , , . $13,817/yr 

Asterisked items are due solelv to presence of add-on control 

($ rates est.) WGM - $50/hr, R.M. & MW.-$35/hr, Env. Mgr-$50/hr 

CAPTURE SYSTEM TECHNICAL DATA 

1. Number of permanent total enclosures (PTE's) that capture HAP emissions 

3. Spray and rollout booth and cure oven, mold makers booth, Nauta mixer 

2. Can the entire building be considered a PTE based on Method 204? 

, V, No 

3. List of HAP emission points captured by each PTE: 

Spray & rollout booth: 2 spray guns, 4 tubs/trays/aprons 

Cure oven: 16 tubs/trays/aprons 

Mold makers booth: 1 spray gun, 1 tub/tray/apron mold 

Nauta mixer 

4. List of HAP emission points not captured by PTE's 

None. 

Resin is mixed 75 percent ofthe time - then pumped to a holding tank. 

Mixed is vented, no openings, filler added in manually. 

II 
P.13 

5. Dimensions of each PTE 

Spray & rollout booth: 

40' x 16' x T 

Cure oven: 

50' x 16' x 5-1/2' 

Mold makers booth: 

16'x16'x8' 

Nauta Mixer: Machineitsejfisye^ 

<*3 

<t>8* x 12' cone truncated at 11* (vol. = 200 Ft) 

6. Dimensions of natural draft openings (NDO's) and face velocity across each: 

Spray & rollout booth: 

Tub entry vestibule: 8' x 5' 282 FPM 

Tub exit 8' x 4' 

Cure oven 

Tub entry 16'x 5' 130 FPM This will be rechecked. 

Tub exit 16'x 5' they could change pulley 

or fan to reach 200 fpm 

Mold makers booth: 12'x 2-1/12' 209 FPM 

Nauta Mixer: 

None 

7. Number of air changes per minute for each PTE 

Spray & rollout booth: 0.220 min per air change 

Cure oven: 0.271 min per air change 

Mold makers booth: 0.326 min per air change 
P.M 

Nauta Mixer: 0.263 min per air change 

8. Measured HAP concentration (ppm) in each PTE: 

Spray & rollout booth: Operator #1 78 ppm(8hrTWA) 

Operator #2 14 ppm (8hr TWA) 

Operator #3 18 ppm (8hr TWA) 

Operator #4 40 ppm (8hr TWA) 

Tests were done 

with collector pumps 

Cure oven: 

Mold makers booth 

Nauta Mixer: 

Not measured (no operator) 

1.2 ppm 

Not measured (no operator) 

9. Number & size of any permanently open doors or any other openings in the PTE 

Spray & rollout booth: None 

Cure oven: None 

Mold makers booth 

Nauta mixer 

10. Basic PTE Materials: 

None 

None 

Spray & rollout booth: Galvanized sheet steel structure, Tempered glass 

Windows. 

Cure oven: Galvanized sheet steel structure 

Mold makers booth 

Nauta mixer: Stainless steel plate 

11. Basic PTE safety equipment: 

Spray & rollout booth: Fire sprinkler system. 

Cure oven: Fire sprinkler system. 

Mold makers booth Fire sprinkler system. 

Galvanized sheet steel structure A little insulation 

on the panels 

No LEL monitors 

\3 
P.15 

Nauta mixer None. 

12. Basic Instrumentation: 

None. 

13. Louvers/Makeup air used with PTE? 

Spray & rollout booth: 

Cure oven: 

Mold makers booth: 

Nauta mixer 

Yes. 

No. 

No. 

No. 

r conditioning used with PTE? 

Spray & rollout booth: 

Cure oven: 

Mold makers booth: 

Nauta mixer 

No. 

No. 

No. 

No. 

Fresh air heat source for wintertime 

15. Does each PTE meet EPA Method 204 criteria for a PTE? 

Spray and rollout booth Yes 

and cure oven 

Mold makers booth Yes 

Nauta Mixer Yes 

16. Method of demonstrating continuous compliance with CE:

 e w

 requirement 

Pressure drop across system 

Polyad operation logs. 

17. Capture efficiency testing requirement: 

has to be maintained and monitored 

Permit renewal and/or at mid point of permit depending on permit language 

when issued. 

CAPTURE SYSTEM COST DATA 

1. Capital cost of PTE's and year of cost data: 

All PTE's $80,000 (1995) 

AMMCOMSkwdard 
P.16 

2. Incremental operating & maintenance costs: 

Filter replacement: 39ea 2x per week, @ $1.50/filter - $117 per week, 

$5850 per year 

1 man-hr per change to replace by operator @ $25/hr - $50 per week 

$2500 per year 

Total: $8350 per year 

DUCTWORK TECHNICAL DATA 

1. Basic ducting materials before and after control device installation: 

Before installation: Galvanized steel, spiral wounc ., , 

Did not change duct work 

After installation: Painted steel when installed controls 

2. Basic ducting configuration before and after control device installation (general 

configuration, length, diameter, location of tees, dampeners, elbows & fans 

q tt , . Before added control just took vent through the roof 

The tub production line had three stacks. 

3. How is ductwork joined prior to add-on control device? *'- ^*. , u» 

Slip joints, w/ sheetmetal screws to complete the connection. All ductwork is 

under negative pressure. All ducts Join on roof to route to the control device 

4. Measured/estimated/assumed velocity of gas stream in ductwork: 

Measured: 

Spray & rollout booth: 1439 FPM (north) 2056 FPM (south) 

Cure Oven: 1681 FPM 

Mold makers booth: 1546 FPM 

Nauta mixer: 4186 FPM 

DUCTWORK COST DATA 

15 
P.17 

1. Capital cost to retrofit ductwork to vent emissions to the control device and year 

of the cost data: 

$36,000 

2. Freight cost & sales tax for ductwork retrofit: 

Not broken out 

3. Incremental electrical power consumption and cost associated with duct fan 

operation due to installation of add-on control device. 

2 1-1/2 HP motors, cost not tracked. Booster fans on cure ovens and sprav booth. 

4. Incremental ductwork maintenance costs due to installation of add-on control 

device. 

None 

5. Incremental ductwork overhead, property tax, insurance, and administration cost 

due to installation of add-on control device: 

None. 

AtowicmStandard 
•• 03/17/00 08:47 FAX 13303372235 P.U 

Attachment 2 

jfotMicanStandard 

FAX TRANSMISSION 

iffluiu 

s-i, 'f i E? 0 | )§ f -f . 

TO: 

CO.: 

PHONE: 

FAX: 

DATE: 

Mr. Keith Barnett 

U.S. EPA 

919-541-3470 

17-Mar-00 

FROM: 

CO: 

PHONE: 

FAX: 

PAGES: 

l BillWelftoan i * 

AMERICAN STANDARD INC. 

605 S. ELLSWORTH AVE. 

SALEM, OH .44460-

0Os332#5& -• * 

330-337-2235 

r 10n: 

MESSAGE: 

Keith- ^ | : 

Here is the October 10,1997 test report showing a destruction efficiency of 94.7% 

We are scheduled for the 23rd to conduct the new efficiency tests#©tfe Tigris il^-0j|it#i Machuga of 

Ohio EPA found copies of findings and orders signed by us (but prior to mylfehurejtthat Specify total VOC 

D.E. tests. There were no copies in my files. ?• * '": 

So, we are now gearing up for method 25a tests. ; ' ' ] 

The findings and orders also require capture efficiency tests. VMwillnot be able to perform the capture 

efficiency tests concurrent with the D.E. tests due to timing of the-testing company. I hop6 they find that 

acceptable. 

If you have any questions let me know. 

Thanks, ; . * **/ ;' * ;; -';' 

*'f- i; 9::;f€: i->-, i SV 

\7 
p.19 

03/17/00 08:47 FAX 13303372235 AMER STANDARD ? |g]002 

OCT-10-9 7 02:4 S PM OPTIMA L TECH 4 1 2 828733 8 P.0 2 

DRAFT • 1 

DESTRUCTION EFFICIENCY REPORT 

AMERICAN STANDARD ^ 

SALEM, OHIO 

October 10,1997 

Project No. 455-12*1002 

Prepared for: 

American Standard 

605 South Ellsworth Avenue 

Salem, Ohio 44460 

Prepared by: 

Optimal Technologies; Incorporated 

575 William PitdWay 

Pittsburgh, Pennsylvania 15238 

(412)828-7330 

\ « 
— P ?n 

03/17/00 08:47 FAX 13303372235 AMER STANDARD ^wa 

OCT-16-97 82:30 PM OPTIMAL TECH ,-412 8287338 P.03 

TABLE OF CONTENTS 

a 

1.0 EXECUTIVE SUMMARY ;..'. iU U.—.-- 1 

SUMMARY OF RESULTS •••• - • 2 

Run No. 1 »~ • >1 

Run No. 2 2 

Run No. 3 ; =• 2 

2.0 TEST PROCEDURES , ;. .... 3 

3.0 QUALITY ASSURANCE , 4 

ATTACHMENTS 

1. Sample Stream Flow Calculations and Total Hydrocarbon Analyzer Measurements 

2. Field Data Sheets and Proecss Infonnation 

3. Quality Assurance 

4. Laboratory Results 

fl 
P.21 

U3/1Y/UU ua:4 B EAA Li 6US3I ZZZS AfflliK STANUAKD j ig-rjUl 

OCT-10-9 7 02:5 8 PM OPTIMA L TECH 412 828733 8 P - 0** 

-S American Standard 

i. ^5; Saltm, OH Facility 

y L. %i Ml DRAFT DG Report 

1.0 EXECUTIVE SUMMARY 

American Standard operates an acrylic and fiberglass bathing ves«)= manufacturing facility in 

Salem, Ohio. During ihe- manufacturing, and coating processes, volatile organic compounds 

(VOCs) either evaporate into the air or arc driven ofl' whilc4hside ovens. TS»e VOCs emitted by 

these processes arc collected by hoods or booths and are directed.tojthe co$f6l device. 

It was the intent of American Standard UJ perform Destruction Efficiency (DF.) testing for the 

bathing vessel manufacturing process Unes at its Salem, OH facility.;The*puiposc of DE testing 

was to determine the destruction efficiency ofthe captured volatile organic; compound (VOC) 

emissions in the conlrol system (incinerator). 

? »- -. 'fit- i •• %|- j - . « . 

Optimal Technologies, Inc. (Optimal) was hired by American Standard tojpcrfbrm Destruction 

Efficiency (DE) tesiing at this facility. This report describes specific lest procedures followed 

during DE testing on American Standard's control devices WhcfC! practical; the principals of 

United States Environmental Protection Agency (EPA) Mbthodsr:2ithrough 4 were utilized to 

measure the volumetric flow rale, oxygen (Oj), carbon dioxide (COj), and moisture content of 

the gas streams. Optimal performed DE testing utilizing loUilihyd^carborv (THC) analyzers with 

flame ionization detectors (FIDs) complying with the tests guidelines described in U.S. EPA's 

Method 25A, Determination of Total Caseous Organic Concentration Usintf a Flame Ionization 

Analvzer. During the DE testing, appropriate process-lines were operating under required 

conditions. Optimal also collected one gas stream sample from thciinlct and outlet for each test 

run to determine methane and acetone concenlralions. Tedlar* bags were used to contain the gas 

stream samples. 'Ilic samples were sent to two qualified --air quality laboratories: for analyses of 

methane and acetone content. The results of the analysis enabled Optimal to subtract off any 

methane and acetone contribution to FID concentration output*. 

The average of three runs the incinerator DE is 94.7%. All results are reported as propane 

equivalent. 

?£> 
— p?? 

03/17/0 0 08:4 8 FAA 13303372Z35 AMEK STAISDAK1) . ^ *Ir. ... „ IgJOUd 

OCT - ia-9 7 02:3 1 PM OPTIMAL TECH 412.e28T3 ? 3 > P. 0 3 

•- h \ American Standard 

".. ; K Salmn, OH Facility 

s l ?V. DRAFTDEReport 

SUMMARY OF RKSULTS 

R "" No- > 

Average Inlel Concentration (as propane) ~.~ -... .«•.*• • 245 pptn 

Average Outiet Concentration (as propane) ...» ...... •••«} • ^ PP m 

Inlet Methane Concentration (as propane)....,*.;..* ».,.«• "TM~ • 1-5 ppm 

Outlet Methane Concentration (as propane)r .^..>.......;..:. ^j. 1.2 ppm 

Inlet Acetone Concentration (as propane) ......L...........U ;;?.L.......i 18.8 ppm 

Oullet Acetone Concentration (as propane)....:.......... .;.. 4.8 ppm 

Destruction Efficiency (with methane/acetone compensation) .............................94.4% 

Run Ntt. 2 

Averag e Inlet Concentration (as propane) .-. LL... .UL. 248 ppm 

Average Outlet Concentration (as propane).... , 19 ppm 

Inlet Methane Concentration (as propane).....!... 'LL,,.. f.;.;.,....,,,.. 0.6 ppm 

Outlet Methane Concentration (as propane).., 1.3 ppm 

Inlel Acetone Concentration (as propane) .....J ;...... 3.7 ppm 

Outlet Acetone Concentration (as propane):*sj^ „-,.*. §.,.-. .' 5.5 ppm 

Destruction Efficiency (with methane/acetone compensation) ..............94.9% 

R an No. 3 

Average Inlet Concentration (as propane) .*. 275 ppm 

Average Outlet Concentration (as propane) ,-«w...*.......f.i.,:j..„.1^y.„i,„.,- 20 ppm 

Inlct Methane Concentration (as propane)...vi...;. ,*„ j-.*.i 3.6 ppm 

Outlet Methane Concentration (as propane).: ..; .,..

;

; : 4.0 ppm 

Inlet Acetone Concentration (as propane) .^L,..........^.; ^..........; 2.5 ppm 

Outlet Acetone Concentration (as propane)..-..... , 2.4 ppm 

Destruction Efllcicncy (with methane/acetone compensation) ,;ui......—..............94.7% 

Refer to Tables 1 and 2 for the DE calculations as well as methane and acetone concentrations. 

2-1 
:

 P.23 

UJ/X//U U ua:4B FAA UJUJ^^J D ASUIK SIAINUAKU nauuo 

OCT-18-97 02:52 PM OPTIMAL TECH 412 e ^ 735 f P. 06 

* /tmerteon Srunt/arrf 

; Salam. OH Facility 

is, ..il l

 : DRAFTDFfReport 

2.0 TEST PROCEDURES -

This scction describes specilic test procedures followed during prejiminap ?DE testing on the 

incinerator. During the DE testing, the process lines were opersUihg at€ill capacity. The 

principals of F.PA Methods 2 through 4 were utilized ^measure :thc voJumetric flow rate, 

oxygen (O,), carbon dioxide (C02), and moisture content ofrwich oiihe fiv^iiilct g& streams and 

the single outlet gas streams. - L\ \- ; *f •! " ffl S f 

To determine the DF. uf the incinerator, measurement of thennlet and outlet (incinerated) THCs 

took place inside the ductwork , before and after the incineration pipocss. ^Two THC analyzers 

with FIDs with healed sample trains continuously measurcdf the THCs entering and exiting the 

incinerator. Clean stainless steel probes were inserted into the gas :?tiicam;f|(inlet and outlet) and 

attached to the healed sample lines (IISEs). Tliis samphng procedure followed the principals 

described in GPA Method 25 A. Optimal uUlixed JUM Mddtl^E#JDK#jteroD/HSL sample 

train measured the THCs in the sample stream from the inlet of the control device. The otiier 

FID/HSL sample train measured THCs in ihe sample stream exiting theieutietlof the control 

device. The concentrations were continuously measured a^rc-porac*! ey||jr thirty seconds by a 

datalogger, Each FID was calibrated to propane as described in lfe method. DE test sampling, 

was performed over three 1-hour .sampling runs. Spreadsheets iri Attachment I list the THC 

emission concentrations for each lest run. Attachments 2 and 3 contain the field data sheets and 

quality assurance information, respectively. 

Tedlar* bags were used to collect gas stream samples lobe analyzed for methane and acetone 

content. Optimal sent the gas samples to experienced andflualifie4 laboratories to bc analyzed 

for methane content and acetone. The samples were analyzed within 72 hours of (collection. The 

gas samples were analyzed by gas chromatography (OC) which has an FID calibrated with 

methane calibration gas. Optimal's JUM Model VE7 FEDs have a 43.21% response factor for 

methane when calibrated witb propane. Therefore, concentrations of methane (calibrated as 

methane) will be converted to an "as propane" response and subtracted from the average FID 

outputs. Optimal's JUM Model VE7 FIDs have a 120% response factor for acetone when 

calibrated with propane, Therefore, concentrations of acetone (calibrated as acetone) will be 

convened to an "as propane" response and subtracted from Ithe average FID outputs. 

Attachment 4 contains laboratory analyses results. iU 

Zi-
P.24 

03/17/00 08:49 FAX 13303372235 AMER STANDARD •>{>• @007 

OCT-ia-9 7 02:5 2 PM OPTIMA L TECH 41 2 8*2873^8 P. 0T 

American Standard 

Salem, OH Facility 

J DRAFT DE Reptirt 

3.0 QUALITY ASSDR4^E | 

Ouality assurance of the FID was determined by inh«#^^ns.tff»p ^ bias cheste, 

JKuHif t checks, and determination of response ^ff^m^^ l 

Z test run with zero air from a specialty gas supplier «^^ 1

t

^.^ r^«^S?? I 

(low, middle, and high range) of propane. Secondly, a sample biu ^.^Jf*^* J 

comparing ihc calibration gas response through the samplc^aw ^ 4ircc^wU^c "^rwnent. 

R^ns e times for one sample line (per instrument) was detennined prior toahe first test run and 

needed. At the end of each test, rsro air and one representative calibration concentration was 

Educe d to each FID to detennine calibration drift. All, calibration^ is contained in 

Attachment 3. 

23 
. P.25 

03/17/00 08:49 FAX 13303372235 AMER STANDARD 1&008 

0CT-10-9T 02:53 PM OPTIMAL TECH * 1 2 SS^TSSS 

TABLES 

V\ 
03/17/00 08:49 FAX 13303372235 AMER STANDARD 

OCT-10-97 02:53 PM OPTIMAL TECH 4 1 2 628T33 8 

P.26 

lg|UUH 

P . 0 9 

TABLE 1 1 H 

AMERICAN STANDARD ; 

SALEM OWO FACILITV. ^ •.. 

DESTRUCTION EFMC1ENCY TE6T 

September 16,1997 

Destruction Effirkne j* RtrnKs** I 

itl methane and aceton* rempMiattoa* 

m^ 

• •: m tf 

III 

IOI 

Point 

Nime 

Incinerator Inlct 

Incinerator OulWi 

| |]] 1 Incinerator Inlel 

1 IOI Incinerator Oullel 

Ul 

101 

VOC Deitruct 

•^:;.*3Poi»it.J .... 

if?fmu'....'s. 

111 

101 

Incinerator Inlct 

i Incinerator Outlet" 

ion Efficiencies From Each Int 

Po'nt 

Name 

Incinerator Inlct 

Incinerator Ouilei 

III Incinerator Inlet 

IOI Incinerator Outlet 

1 <" 

L

 l01 

Incinerator Inlet 

Incinerator Outlet 

Teit 

Run 

1 

1 

2

 I ' 2 1 

3 

3 

.inerator (kg/kg 

• "*" -Test 

Run 

1 

1 

"ctff 

_Jg£l«) 

2247 

ll' 

243.7 

12.2 

268.5 

13.1 

> 

C(Fj) 

219. 

Ifl. 

1 T 

1 2 

236 

" 

[ 3 | 262 

1 3 1 13 

C(DO),J 

1 

0.6 

J .' i '-.-» : 

1 : 0.4 

• •'•&&&.': . 

5053 -

» # 

5<&5 

25.1 

...:S& . 

494 

24.4 

, 

494 

24.4 

-. . •::•-"-•?,j?*-r: |^-? ' vK^t**- ;.----y-

:••':!* '•*-• JI 

1 ... o.i? 

: *: "*:! 

.. ...........r....... 

0 .738.1 8 

0 <• 873.0 6 

2~[ ? »i.6J 

7l S51.73 

9 ? 7*4.4: 

.0 .; 847.3: 

- -. -i" • ,. * :: 

15 "j Stm\ * 494 

|f : L-HM i 24.4 

y.<cM "•'. 

219.0 

10.0 

236J] 

11.7| 

262.9 

13.0 

^lifc.;".'-

160 

60 

' +:mi : 

'. 1.83E-06 

1.S3E-06 

•y:.nm...:; 

•.^•KWift " ••-••• 

17.8 

1.0 

Run #1 DE*= 94.4% 

I; f 60 l.B3E-00| 21.6 

: | • « 1.83E-OOI It 

Ru*a#2DE= 94.9% 

t « 

»• 6( 

vj -s s- '3. ? .. 

1 I.83E-06 22.6 

) 1.83K-06 1.2 

RonWDE- 94.7V. 

AVERAGE DE = 

WHERE: 

C(rj) = corrected average VOC concentrations of emissions at poinl j, ppm propane • 

CQ) ***= coiTectcd (for mefnune and ncewme) average VOC concentrations measured appoint j. ppm propane . 

C(DO) = average system drill cheek concentration for Mro concentration gas. ppm propane 

C(ni I) -• average measured concentration for the drift check calibration fc.is, ppm propane 

QH)*-actual concentration or ilic drill eittCk calibration &s, ppm propane -•• * = i *. \ \ 

C(fj) [C(jVC{I)0)lx[lC(HVlC(l>Hl-C(DO)ll - I -

F(BJ)- total VOC content of emissions from point j, leg C(F.i)xQ(F.J)xT(F)xK.(1) 

Q(Fj) = average elTlociH volumetric flow rate corrected to standard conditions w poln^, m3/miiv»dscftn x 0.0283 

T(F) = total durntion of sampling run. min. * 

K(l) - 1.83 x 10E-6 kn/(m3*ppm) (factor for propane)

 : e 

94.7V. 

15 
03/17/00 08:49 FAX 13303372235 AMER STANDARD 

OCT-10-97 02:54 PM OPTIMAL TECH 

:

* 1 2 S28T3yS 8 

P.27 

IgJUlU 

P . 1 0 

TABLE 2 

AMERICAN STANDARD 

SALEM OHIO FACILITY 

DESTRUCTION EFNCIKNGvroS* 

September 16,l-HT/v ; 

Destruction Efficiency Results • 

methane and acetone conscntratkOM^ 

FID Response Facton 

Methane -43% 

Acetone 

Run No. 1 

Methane 

Acetone 

Rvn No. 2 

Methane 

Acetone 

Run No. 3 

Methane 

Acetone 

=120% 

Concentration (ppm) 

Concentration (ppnl) 

Concentration (ppm) 

Concentration (ppm) 

Concentration (ppm) 

Concentraiion (ppm) 

LvbReaults JS. M Propane 

lntel«'A&itl«iftJ--lBl#I •• tOirtlet 

3§i.4i.*52§|. 'H? ; ; 1 I-2 

mi it*

 ?

V5i« 4.8 g 

1.5 

3.1 

8.4 

2.1 

3d* 

4 * 

2v0* 

3>6 

sm 

1.3 

5.5 

4.0 

2.4 

Zj^ 
P.28 
P.29 

AMERICAN STANDARD, INC. 

BUILDING &< PRDPERTY 

605 SDUTH ELLSVDRTH AVE. 

SALEM, DH 44460 SCALE: l'=24' 

J 

L CARGD ELEVATDR 

LL 

8-

STAIRS 

\ " 

MAN ELEVATDR 

bl 

1 

> 

C£ 

• 

LJ 

3 • 

00 

J / 

MULLINS STREET 

^§^ 
P.30 

Emiaaion Teat Report Attachment 4 American Standard, Inc 

U.S.EPA Methods 2 4 4 

0*Hm*«K)« of SlKfc O M Vatodty. VoUnattc fkm Rrt. •nd Mows* Ccntvt 

TaMSni: Martcan Stvdvd 

EirtWenUNt POIYAD Syttan 

Procti a Information 

SUMMARY RESULTS 

Test Run Start Time (hr:min): 

Test Run Stop Time (hr:min): 

POOS 

11:09 

11:12 

ES28 

10:59 

11-02 

TMtDsto: 

JobNuitxr 

North#2 

Rooe 

10:43 

10:49 

V27/X 

KOSOSAJ 

South #1 

ROOS 

10:30 

10:37 

B21S 

10:30 

10:41 

Stack Ga i Condition! 

Average Stack Gas Temperature (ts) (*F) 

Average Stack Gas Static Pressure (ps) On H20) 

Wet Volumetric Stock Gas Fiow at Actual Conditions (Qaw) (acfm) 

Dry Volumetric Stack Gas Flow at Standard Conditions (Qstd) (dscfm) 

Average Stack Gas Velocity (Vs) (ft/min): 

Percent by Volume Moisture as measured in Stack Gas (%H20) 

Nonnal Air Percent by Volume Carton Dioxide in Stack Gas (Dry Basis) (% C02) 

Normal Air Percent by Volume Oxygen in Stack Gas (Dry Basis) (%02) 

Normal Ak Percent fay Volume Carbon Monoxide in Stack Gas (Dry Basis) (%CO) 

Normal Air Percent by Volume Nitrogen in Stack Gas (Dry Basis) (%N*2) 

Normal Air Percent by Volume Argon in Stack Gas (Dry Basis) (%Af) 

87.00 

5.00 

822 

759 

4.186 

1.91 

0.03 

20.95 

0.00 

78.08 

0.93 

92.00 

0.40 

1,321 

1.193 

1,681 

1.99 

0.03 

20.95 

0.00 

78.08 

0.93 

62.00 

-0.97 

9.072 

8.332 

1.439 

1.84 

0.03 

20.95 

0.00 

78.08 

0.93 

78.00 

-0.67 

12.961 

12,015 

2.056 

1.74 

0.03 

20.95 

0.00 

76.08 

0.93 

75.00 

0.70 

6.730 

6.269 

1,546 

1.64 

0.03 

20.95 

0.00 

78.08 

0.93 

Tait Results 

Average Velocity Pressure (Delta P) (in H20): 1.044 0.166 0.171 0.352 0.144 

AJrComptlanc* Tnting CONFIDENTIAL - 10/11/96 

I] 7Pj 

Page 15